Privacy Policy

Last updated: 17th July 2025

This Privacy Policy describes how 'a different conversation' (referred to as "we", "us", or "our") collects, uses, and discloses your personal data when you visit our website (the "Site") and interact with our services. We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the UK GDPR.

1. Who We Are

'a different conversation' is a life and business coaching service provided by Malachy Donaghy.

Contact Details:

• Email: malachy.donaghy@gmail.com
• Mobile: 07484 220395

2. Data We Collect

We may collect and process the following types of personal data:

• Identity Data: Name, title.
• Contact Data: Email address, telephone number, address.
• Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data: Information about how you use our website, products, and services.
• Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
• Enquiry Data: Information you provide when you make an enquiry through our contact form or directly via email/phone, including your area of interest for coaching.

3. How We Collect Your Data

We use different methods to collect data from and about you, including:

• Direct interactions: You may give us your Identity, Contact, and Enquiry Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
  • Enquire about our products or services.
  • Subscribe to our newsletter.
  • Request marketing to be sent to you.
  • Provide feedback or testimonials.
• Automated technologies or interactions: As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for more details.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google.

4. How We Use Your Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To respond to your enquiries and provide you with the information or services you request.
• To send you newsletters and marketing communications if you have opted in to receive them.
• To improve our website and services through analysis of usage patterns.
• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
• To comply with legal or regulatory obligations.

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

• Purpose: To register you as a new client or respond to your enquiry.
  • Type of data: Identity, Contact, Enquiry.
  • Lawful basis for processing: Performance of a contract with you or taking steps at your request before entering into a contract.
• Purpose: To manage our relationship with you, which will include:
  • Notifying you about changes to our terms or privacy policy.
  • Asking you to leave a review or take a survey.
  • Type of data: Identity, Contact, Profile, Marketing and Communications.
  • Lawful basis for processing: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
• Purpose: To enable you to participate in a prize draw, competition, or complete a survey.
  • Type of data: Identity, Contact, Usage, Marketing and Communications.
  • Lawful basis for processing: Performance of a contract with you; Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
• Purpose: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
  • Type of data: Technical, Usage.
  • Lawful basis for processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation.
• Purpose: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  • Type of data: Identity, Contact, Technical, Usage, Profile, Marketing and Communications.
  • Lawful basis for processing: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
• Purpose: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
  • Type of data: Technical, Usage.
  • Lawful basis for processing: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

5. Disclosure of Your Data

We may share your personal data with:

• Service providers who provide IT and system administration services.
• Professional advisors including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• HM Revenue & Customs, regulators, and other authorities based in the UK and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We do not currently transfer your personal data outside the UK or European Economic Area (EEA). If we do, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or UK government.
• Where we use certain service providers, we may use specific contracts approved by the European Commission or UK government which give personal data the same protection it has in Europe/UK.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• The right to be informed: You have the right to be informed about the collection and use of your personal data.
• The right of access: You have the right to request a copy of the personal data we hold about you.
• The right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• The right to erasure ("right to be forgotten"): You have the right to request that we delete or remove personal data where there is no good reason for us to continue to process it.
• The right to restrict processing: You have the right to request that we suspend the processing of your personal data in certain scenarios.
• The right to data portability: You have the right to request the transfer of your personal data to you or to a third party.
• The right to object: You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• The right to withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time.

If you wish to exercise any of the rights set out above, please contact us at malachy.donaghy@gmail.com.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Changes to This Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on 17th July 2025. Historic versions can be obtained by contacting us. Any changes will be posted on this page, and where appropriate, notified to you by email.

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

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